Assessing Value Creation for Transfer Pricing

WTP Advisors Transfer Pricing specialists Kash Mansori and Guy Sanschagrin discuss BEPS and determining where value is created. While three of the BEPS working groups were tasked with “aligning transfer pricing outcomes with value creation” the reports do not define value creation. This may lead to unintended consequences of misinterpreting the guidance by companies and tax authorities, and placing more burden on companies and their transfer pricing team as the scope is not defined. In the end, it means that more work needs to develop a more comprehensive framework to evaluate transfer pricing arrangements. Read the full article that appeared in the March 28, 2016, edition of Tax Notes International, published by Tax Analysts